Privacy Policy

1. Who We Are

LeadWise B.V. is a private limited company incorporated under Dutch law, with its principal place of business in Zeist, The Netherlands. We operate the website at www.leadwise.app and provide leadership development products including the Emerging Leaders Program and the Lisa AI management coach.

For the purposes of the GDPR, LeadWise B.V. is the data controller responsible for your personal data.

Contact: info@leadwise.app

2. Data We Collect

Data you provide directly

• Account data: name, email address and password when you register.
• Purchase data: name, email, billing address and payment information. We do not store full card numbers.
• Self-assessment data: your answers to the 60-statement manager self-assessment and the name and email you submit with it.
• AI coach interactions: the questions and messages you send to Lisa, our AI management coach.
• Contact and enquiry data: information you send via our contact forms or by email.

Data collected automatically

• Usage data: pages visited, time spent, features used, progress through the program.
• Device and browser data: IP address, browser type, operating system, device type.
• Cookies: see Section 9 for details.

3. How We Use Your Data

• To create and manage your account and provide access to our products.
• To process payments and deliver the Emerging Leaders Program.
• To generate and deliver your personalised self-assessment report by email.
• To operate the Lisa AI management coach and provide coaching responses.
• To send transactional emails such as purchase confirmations and report delivery.
• To respond to your enquiries and support requests.
• To improve our products through anonymised usage analytics.
• To comply with our legal obligations.

We do not use your data for targeted advertising. We do not sell your personal data to third parties.

4. Legal Basis for Processing

• Contract performance — to deliver the products and services you have purchased.
• Legitimate interests — to improve our products, prevent fraud, and communicate with you about your account.
• Legal obligation — where required by applicable law (e.g. tax and accounting obligations).
• Consent — where we explicitly ask for your consent, such as for optional marketing emails. You may withdraw consent at any time.

5. Sharing Your Data

• Service providers: trusted third-party providers for hosting, payment processing, email delivery and analytics. These providers act as data processors under our instruction.
• AI service providers: your interactions with Lisa may be processed by our AI technology partner. Coaching conversations are not used to train external models without your explicit consent.
• Legal requirements: we may disclose your data where required by law or court order.
• Business transfers: in a merger or acquisition, your data may be transferred. We will notify you before it becomes subject to a different privacy policy.

6. International Transfers

Some of our service providers are based outside the EEA. Where we transfer personal data outside the EEA we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

You may request a copy of the relevant safeguards by contacting us at info@leadwise.app.

7. Data Retention

• Account data: retained for the duration of your account and up to 3 years after closure.
• Purchase and financial records: retained for 7 years to comply with Dutch tax law.
• Self-assessment responses: retained for up to 2 years.
• AI coach interactions: retained for up to 12 months after your access period ends, then anonymised or deleted.
• Marketing consent records: retained for as long as you remain subscribed and for 3 years after you unsubscribe.

8. Your Rights

Under the GDPR you have the right to access, rectify, erase, restrict, port and object to the processing of your personal data. You also have rights related to automated decision-making.

To exercise any of these rights, email us at info@leadwise.app. We will respond within 30 days. We may need to verify your identity before processing your request.

9. Cookies and Tracking

• Strictly necessary cookies: required for the website and platform to function. These cannot be disabled.
• Analytics cookies: help us understand how visitors use our site. We use anonymised analytics and do not share this data with advertising networks.
• Functional cookies: remember your preferences to personalise your experience.

You can manage cookies through your browser settings. We do not use cookies for targeted advertising.

10. Children's Privacy

Our products are intended for adults in professional roles. We do not knowingly collect personal data from anyone under the age of 16. If you believe we have inadvertently collected data from a minor, please contact us at info@leadwise.app and we will delete it promptly.

11. Complaints

If you have a concern about how we handle your personal data, please contact us first at info@leadwise.app and we will do our best to resolve it.

You also have the right to lodge a complaint with the Dutch Data Protection Authority: Autoriteit Persoonsgegevens — www.autoriteitpersoonsgegevens.nl

12. Do-Not-Track

Some browsers include a Do-Not-Track (DNT) setting. No uniform technology standard for recognising DNT signals has been finalised and we do not currently respond to DNT signals. If a binding standard is adopted we will update this policy accordingly.

13. US Residents

If you are a resident of California, Colorado, Connecticut, Utah or Virginia you may have additional rights under applicable state privacy laws, including the right to know what data is collected, the right to deletion and the right to opt out of the sale of personal data.

We do not sell your personal data. To exercise any applicable rights, email us at info@leadwise.app.

14. Other Regions

Australia and New Zealand

We process personal data in compliance with Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. Complaints may be submitted to the relevant national privacy commissioner.

Canada

We process personal data in accordance with applicable Canadian privacy legislation including PIPEDA.

Republic of South Africa

You have the right to request access to or correction of your personal data at any time. Complaints may be submitted to the Information Regulator of South Africa.

15. Updates to This Notice

We may update this privacy notice from time to time. The updated version will be posted on this page with a revised date at the top. If we make material changes we will notify active users by email or platform notification.

16. How to Contact Us

If you have questions, concerns or requests relating to this privacy notice or your personal data, please contact us:

• Email: info@leadwise.app
• Company: LeadWise B.V.
• Address: Zeist, The Netherlands

To review, update or delete your personal data, email us at info@leadwise.app.